ML16280A200

Response to Request for Additional Information Related to the Pressurized Water Reactor Internals Program Plan for Aging Management of Reactor Internals

ML16280A200
Person / Time
Site:	Robinson
Issue date:	10/05/2016
From:	Glover R Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME9633 PWROG-14018-NP
Download: ML16280A200 (11)

Text

R. Michael Glover H B Robinson Steam Electric Plant Unit 2 Sile Vice President Duke Energy Progress, LLC 3581 West Entrance RoacJ Hartsville, SC 29550 0 843 857 1704 F 843 857 1319

!tlike.Glm*rt@1/uke-energy.. cam 10 CFR 54.21 10 CFR 2.390(b)(4)

Serial: RNP-RA/16-0081 OCT 15 201&

ATTN: Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555-0001 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261/RENEWED LICENSE NO. DPR-23 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE PRESSURIZED WATER REACTOR INTERNALS PROGRAM PLAN FOR AGING MANAGEMENT OF REACTOR INTERNALS <TAC NO. ME9633)

References:

1. NRC E-Mail, Unit 2 PWR Vessel Internal Program Plan for Aging Management - Request for Additional Information (RAls) (TAC No. ME9633) , dated August 27, 2013, (ADAMS Accession Number ML13240A499)

2. H.B. Robinson Steam Electric Plant, Unit 2, Response to NRG request for Additional Information Related to the Pressurized Water Reactor Internals Program Plan for Aging Management of Reactor Internals (TAC No. ME9633), dated October 01, 2011, (ADAMS Accession Number ML14287A222)

Ladies and Gentlemen :

By e-mail dated August 27, 2013, the NRC requested that Duke Energy Progress, LLC, respond to a request for additional information (RAI) regarding the Aging Management Program for the Reactor Vessel Internals at H. B. Robinson Steam Electric Plant (HBRSEP), Unit No. 2 [Reference 1]. The Duke Energy Progress response to the NRC's request was provided in the letter dated October 1, 2014 [Enclosure 3 to Reference 2]. The vendor provided an affidavit in enclosures 1 and 2 to Reference 2, which requested withholding of the proprietary information contained in to Reference 2, from public disclosure, in accordance with paragraph (b)(4) of Section 2.390 of the commission's regulations.

The vendor has removed the proprietary information from Enclosure 3 of the October 1, 2016, submittal and has developed a non-proprietary version . The resulting non-proprietary response is hereby submitted as the enclosure to this letter.

United States Nuclear Regulatory Commission Serial: RNP-RA/16-0081 Page 2 of 2 There are no regulatory commitments made in this submittal. If you have any questions regarding this submittal, please contact Mr. Tony Pila, Manager (Acting) - Nuclear Regulatory Affairs at (843) 857-1409.

I declare under penalty of perjury that the foregoing is true and correct.

Executed On: OcJ-.obcr G' I1 ::io I~

Sincerely, A *tv1 I~~ J;de~

R. Michael Glover Site Vice President RMG/am

Enclosure:

H. B. Robinson Unit 2 Summary Report for the Fuel Design I Fuel Management Assessments cc: NRC Resident Inspector, HBRSEP Unit No. 2 NRC Regional Administrator, NRC, Region II Dennis Gavin, NRC Project Manager, NRR

United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RA/16-0081 9 Pages (including cover page)

H. B. Robinson Steam Electric Plant, Unit No. 2 H. B. Robinson Unit 2 Summary Report for the Fuel Design I Fuel Management Assessments

PRESSURIZED WATER REACTOR OWNERS GROUP PWROG-14018-NP Revision 0 WESTINGHOUSE NON-PROPRIETARY CLASS 3 H. B. Robinson Unit 2 Summary Report for the Fuel Design I Fuel Management Assessments Materials Committee PA-MSC-0983, Revision 1, Task 7 August 5, 2014

@Westinghouse

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WESTINGHOUSE NON-PROPRIETARY CLASS 3 PWROG-14018-NP Revision 0 H. B. Robinson Unit 2 Summary Report for the Fuel Design I Fuel Management Assessments PA-MSC-0983, Revision 1, Task 7 Eugene T. Hayes*

Radiation Engineering and Analysis Reviewer: Melissa A. Hunter*

Radiation Engineering and Analysis Approved: Marc D. Grider*, Manager Radiation Engineering and Analysis Approved: James P. Molkenthin*, Program Director PWR Owners Group PMO

• Electronically approved records are authenticated in the electronic document management system.

Westinghouse Electric Company LLC 1000 Westinghouse Drive Cranberry Township, PA 16066, USA

©2014 Westinghouse Electric Company LLC All Rights Reserved

WESTINGHOUSE NON-PROPRIETARY CLASS 3 iii ACKNOWLEDGEMENTS This report was developed and funded by the Pressurized Water Reactor Owners Group under the leadership of the participating utility representatives of the Materials Committee.

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WESTINGHOUSE NON-PROPRIETARY CLASS 3 iv LEGAL NOTICE This report was prepared as an account of work performed by Westinghouse Electric Company LLC. Neither Westinghouse Electric Company LLC, nor any person acting on its behalf:

1. Makes any warranty or representation, express or implied including the warranties of fitness for a particular purpose or merchantability, with respect to the accuracy, completeness, or usefulness of the information contained in this report, or that the use of any information, apparatus, method, or process disclosed in this report may not infringe privately owned rights; or

2. Assumes any liabilities with respect to the use of, or for damages resulting from the use of, any information, apparatus, method, or process disclosed in this report.

COPYRIGHT NOTICE This report has been prepared by Westinghouse Electric Company LLC and bears a Westinghouse Electric Company copyright notice. Information in this report is the property of and contains copyright material owned by Westinghouse Electric Company LLC and /or its subcontractors and suppliers. It is transmitted to you in confidence and trust, and you agree to treat this document and the material contained therein in strict accordance with the terms and conditions of the agreement under which it was provided to you.

As a participating member of this task, you are permitted to make the number of copies of the information contained in this report that are necessary for your internal use in connection with your implementation of the report results for your plant(s) in your normal conduct of business.

Should implementation of this report involve a third party, you are permitted to make the number of copies of the information contained in this report that are necessary for the third party's use in supporting your implementation at your plant(s) in your normal conduct of business if you have received the prior, written consent of Westinghouse Electric Company LLC to transmit this information to a third party or parties. All copies made by you must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

DISTRIBUTION NOTICE This report was prepared for the PWR Owners Group. This Distribution Notice is intended to establish guidance for access to this information. This report (including proprietary and non-proprietary versions) is not to be provided to any individual or organization outside of the PWR Owners Group program participants without prior written approval of the PWR Owners Group Program Management Office. However, prior written approval is not required for program participants to provide copies of Class 3 Non-Proprietary reports to third parties that are supporting implementation at their plant, and for submittals to the NRG.

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WESTINGHOUSE NON-PROPRIETARY CLASS 3 v TABLE OF CONTENTS 1 MRP 2013-025 GUIDANCE TEXT DEMONSTRATING MRP-227-A APPLICABILITY FOR H. B. ROBINSON UNIT 2 REACTOR INTERNALS AGING MANAGEMENT FUEL DESIGN I FUEL MANAGEMENT ASSESSMENTS .................. 1-1 1.1 H. B. ROBINSON UNIT 2 EVALUATION ..... .. ....... ........................... .. ................. 1-1 1.1 .1 Components Located Beyond the Outer Radius of the Reactor Core .. ................ ...... ................ .. ....................................... .. .................. 1-1 1.1.2 Components Located Above the Reactor Core ...... .................. ......... .. 1-2 1.1. 3 Components Located Below the Reactor Core ........ ... ............... ... ... ... 1-2 2 REFERENCES ..... .. ...... ............. .............. ....... ..... .. ... ... .... .......... ....... ... ........................... 2-1 PWROG-1 4018-NP Revision 0

WESTINGHOUSE NON-PROPRIETARY CLASS 3 1-1 1 MRP 2013-025 Guidance Text Demonstrating MRP-227-A Applicability for H. 8. Robinson Unit 2 Reactor Internals Aging Management Fuel Design I Fuel Management Assessments In Request for Additional Information (RAI) 3-1 [1], the U.S. Nuclear Regulatory Commission (NRC) advised Duke Energy Progress that resolution of Applicant/Licensee Action Item (A/LAI) 1 of MRP-227-A would need to be resolved as part of the staff's review of the Aging Management Program for the Reactor Vessel Internals at H. B. Robinson Unit 2, also known as Robinson Nuclear Plant (RNP).

RAl-3-1:

2. Have RNP ever utilized atypical fuel design or fuel management that could make the assumptions of MRP-227-A regarding core loading/core design non-representative for that plant, including power changesluprates? If so, describe how the differences were reconciled with the assumptions of MRP-227-A or provide a plant-specific aging management program for affected components as appropriate.

1.1 H. B. Robinson Unit 2 Evaluation Westinghouse has evaluated the H. B. Robinson Unit 2 (CPL) reactor internals components with regard to fuel designs and fuel management according to industry guideline MRP 2013-025 [2].

H. B. Robinson Unit 2 has not utilized atypical fuel designs or fuel management that could make the assumptions of MRP-227-A regarding core loading/core design non-representative, including power changes/uprates that have occurred over the operating lifetime of the unit. This conclusion is based on comparisons of the H. B. Robinson Unit 2 core geometry and operating characteristics with the MRP-227-A applicability guidelines for Westinghouse-designed reactors specified in MRP 2013-025 [2].

Specifically, the following comparisons with the MRP-227-A applicability guidelines in MRP 2013-025 [2] were established for the key reactor internals components at H. B. Robinson Unit 2.

1.1.1 Components Located Beyond the Outer Radius of the Reactor Core Guideline 1 - The reactor has been operated with out-in fuel management for 30 effective full-power years or less and all future operation will use low-leakage fuel management.

Comparison - H. B. Robinson Unit 2 initiated low-leakage fuel management strategy in the ninth fuel cycle following 7.3 effective full-power years (EFPY) of operation and has been implementing low-leakage core designs since that time. There are no current plans to return to out-in fuel management.

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WESTINGHOUSE NON-PROPRIETARY CLASS 3 1-2 Guideline 2 - For operation going forward the average power density of the reactor core (as defined in MRP 2013-025 [2]) shall not exceed 124 W/cm 3 .

Comparison - For the last seven operating fuel cycles (Cycles 22 through 28), H. B.

Robinson Unit 2 has been operating at a rated power level of 2339 MWt.

For the 157 fuel assembly H. B. Robinson Unit 2 core geometry, the 2339 MWt power level corresponds to a core power density of 90.1 W/cm 3 . This level of power generation is also representative of anticipated future operation.

Guideline 3 - For operation going forward, the nuclear heat generation rate figure of merit (HGR-FOM) (as defined in MRP 2013-025 [2]) shall not exceed 68 W/cm 3 .

Comparison -For the last seven operating fuel cycles at H. 8. Robinson Unit 2, the HGR-FOM at key baffle locations has ranged between [

]a.c. This range of HGR-FOM is representative of anticipated future operation.

1.1.2 Components Located Above the Reactor Core Guideline 1 - Considering the entire operating lifetime of the reactor, the average power density of the core (as defined in MRP 2013-025 [2]) shall not exceed 124 W/cm 3 for a period of more than two effective full-power years.

Comparison -Over the operating lifetime of the H. B. Robinson Unit 2 reactor, the rated core power level, including power uprates, has varied between 2200 MWt and 2339 MWt. This variation of rated power level corresponds to a power density range of 82.9 W/cm 3 to 90.1 W/cm 3 .

Guideline 2 - Considering the entire operating lifetime of the reactor, the distance between the top of the active fuel stack and the bottom of the upper core plate (UCP) shall not be less than 12.2 inches for a period of more than two effective full-power years.

Comparison -For the H. B. Robinson Unit 2 reactor internals and fuel assembly geometry, the nominal distance between the top of the active fuel stack and the bottom of the UCP averaged over the first 28 fuel cycles of operation was [ ]a,c. During that period of time the nominal distance between the UCP and the top of the active fuel was not less than 12.2 inches.

1.1.3 Components Located Below the Reactor Core Based on the discussion provided in MRP 2013-025 [2], plant-specific applicability of MRP-227-A for components located below the reactor core with no further evaluation required is demonstrated by meeting the MRP-227-A, Section 2.4 criteria. The basic assumptions of MRP-227-A, Section 2.4 are met by H.B. Robinson Unit 2.

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WESTINGHOUSE NON-PROPRIETARY CLASS 3 2-1 2 References

1. U.S. NRG Document, "RE: Robinson, Unit 2 PWR Vessel Internal Program Plan for Aging Management - Revised Requests for Additional Information (RAls) (TAC No.

ME9633)," September 23, 2013. (NRG ADAMS Accession No. ML13266A240)

2. EPRI Letter, MRP 2013-025, "MRP-227-A Applicability Template Guideline,"

October 14, 2013.

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